| Re: | Hyperera, Inc. |
| Registration Statement on Form S-1 |
| Request for Acceleration |
| File No. 333-163035 |
| · | Should the Commission of the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| · | The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| · | The company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
| Sincerely, | |
| /s/ Zhi Yong Li, Chairman | |
| Zhi Yong Li, Chairman |
Comment Number | Explanation |
| 1. | Requested information added to Risk Factor, page 11. |
| 2. | Interest of Experts section revised to reflect years covered in financial statements, page 24. |
| 3. | Disclosure in MDA Overview as well as related Risk Factor revised as follows: Risk Factors: Our generating minimal revenues from operations makes it difficult for us to evaluate our future business prospects and make decisions based on those estimates of our future performance. Although we have taken significant steps to develop our business plan since our inception, as of June 30, 2009, we have generated only minimal revenues. Our business plan is still speculative and unproven. There is no assurance that we will be successful in executing our business plan or that even if we successfully implement our business plan, we will ever generate significant revenues or profits, which makes it difficult to evaluate our business. As a consequence, it is difficult, if not impossible, to forecast our future results based upon our historical data. Because of the uncertainties related to our lack of historical operations, we may be hindered in our ability to anticipate and timely adapt to increases or decreases in sales, revenues or expenses. If we make poor budgetary decisions as a result of unreliable historical data, we may never generate revenues or become profitable or incur losses, which may result in a decline in our stock price. MDA Overview Our business is sale of hardware and software and customization of clinical information system software for medical clinics and hospitals in China and throughout Asia. We have been developing our infrastructure to begin to sell the clinical information system software and have generated only minimal sales and revenues as of June 2010. |
| 4. | “Total” Column in Compensation Table completed and compensation revised. |
| 5. | Accounting disclosures were updated to reflect the new FASB Standard Codification became effective on July 1, 2009. All the references to accounting standards were revised and fixed accordingly. See updated accounting disclosures below |
| Pronouncement | Issued | Title |
ASC 855 | May 2009 | Subsequent Events |
| ASC 105 | June 2009 | The FASB Accounting Standards Codification and the Hierarchy of Generally Accepted Accounting Principles—a replacement of FASB Statement No. 162 |
| ASC 820 | August 2009 | Fair Value Measurements and Disclosures – Measuring Liabilities at Fair Value |
| ASC 260 | September 2009 | Earnings per Share – Amendments to Section 260-10-S99 |
| ASC 820 | September 2009 | Investments in Certain Entities that Calculate Net Asset Value per Share (or Its Equivalent) |
| ASC 605 | October 2009 | Revenue Recognition (Topic 605): Multiple-Deliverable Revenue Arrangements – a consensus of the FASB Emerging Issues Task Force |
| ASC 470 | October 2009 | Accounting for Own-Share Lending Arrangements in Contemplation of Convertible Debt Issuance or Other Financing – a consensus of the FASB Emerging Issues Task Force |
| ASC 860 | December 2009 | Transfers and Servicing (Topic 860): Accounting for Transfers of Financial Assets |
| ASC 505 | January 2010 | Accounting for Distributions to Shareholders with Components of Stock and Cash – a consensus of the FASB Emerging Issues Task Force |
| ASC 810 | January 2010 | Consolidation (Topic 810): Accounting and Reporting for Decreases in Ownership of a Subsidiary – a Scope Clarification |
| ASC 718 | January 2010 | Compensation – Stock Compensation (Topic 718): Escrowed Share Arrangements and the Presumption of Compensation |
| ASC 820 | January 2010 | Fair Value Measurements and Disclosures (Topic 820): Improving Disclosures about Fair Value Measurements |
| ASC 855 | February 2010 | Subsequent Events (Topic 855): Amendments to Certain Recognition and Disclosure Requirements |
| ASC 810 | February 2010 | Consolidation (Topic 810): Amendments for Certain Investment Funds |
| ASC 815 | March 2010 | Derivatives and Hedging (Topic 815): Scope Exception Related to Embedded Credit Derivatives |
